Large Bank Examination Workshop February 2026

a. Recommendation: The Bank should pursue a more dynamic approach to modeling

construction and CRE prepay speeds that accounts for the unprecedented events that

are currently impacting market rates and borrower behaviors.

b. Management Response : Management will work with our Profitstar advisor to see if

the prepayment behavior can be isolated in the rising and falling rate environments for

the construction and CRE loans.

c. Resolution Status : TBD

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